Privacy Policy — a45.com

1 Introduction

1.1   a45.com ("the Platform", "we", "us", "our") is committed to protecting the privacy and personal data of all individuals who use our online gaming platform. This Privacy Policy applies to all personal information collected through a45com.biz, including information collected during account registration, KYC verification, payment processing, gameplay, customer support interactions, and any other use of the a45.com platform.

1.2   a45.com operates as a PAGCOR-licensed online gaming platform serving Filipino players across the Philippines, including Metro Manila, Cebu, Davao, Quezon City, and the broader Philippine archipelago. This Privacy Policy is designed to comply with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and applicable PAGCOR data governance requirements.

1.3   This Privacy Policy should be read alongside the a45.com Terms & Conditions and Responsible Gaming Policy, all of which form part of the agreement between you and a45.com. By registering an account or using any feature of the a45.com platform, you confirm that you have read and understood this Privacy Policy.

2 Data Controller

2.1   For the purposes of the Philippine Data Privacy Act of 2012, the data controller responsible for your personal information collected through a45.com is the licensed operator of the a45com.biz platform (hereafter "the Operator"). The Operator holds a valid PAGCOR license authorising the operation of an online gaming platform for Filipino players.

2.2   The Operator has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with RA 10173 and this Privacy Policy. Contact details for the DPO are provided in Section 16 of this Policy.

2.3   The Operator has registered its data processing activities with the National Privacy Commission (NPC) of the Philippines as required under RA 10173 and applicable NPC circulars.

3 Personal Data We Collect

3.1   a45.com collects the following categories of personal data, depending on how you interact with the platform:

3.2   a45.com does not intentionally collect sensitive personal information (as defined under RA 10173, including racial or ethnic origin, political opinions, religious beliefs, health information, or criminal records) unless directly relevant to a regulatory compliance obligation or a specific responsible gaming assessment.

4 How We Collect Your Data

4.1   Directly from you. The majority of personal data a45.com holds is information you provide directly — during registration, during KYC verification, when you contact support, or when you set responsible gaming limits on your account.

4.2   Automatically during your use of the platform. Technical and usage data is collected automatically when you access a45.com using standard web technologies, including server logs, session cookies, and browser storage mechanisms. This data is used for security monitoring, platform performance, responsible gaming analysis, and fraud detection.

4.3   From payment service providers. When you make a deposit or withdrawal via GCash, Maya, BPI, BDO, or another accepted payment method, a45.com receives transaction confirmation data from the relevant payment provider. a45.com does not receive or store complete GCash or bank account credentials — only the reference data necessary to reconcile the transaction.

4.4   From regulatory and identity verification services. In connection with KYC verification and anti-money laundering compliance, a45.com may verify identity information against third-party identity validation services or Philippine government databases where permitted by law.

5 How We Use Your Personal Data

5.1   a45.com uses personal data for the following purposes:

• Account management: Creating and maintaining your a45.com account, authenticating your identity at login, and administering account settings including responsible gaming tools.
• Payment processing: Processing deposits via GCash, Maya, and bank transfers; processing withdrawal requests; reconciling transactions; and detecting unauthorised or fraudulent transactions.
• PAGCOR regulatory compliance: Fulfilling obligations under PAGCOR operating conditions, including mandatory player reporting, transaction monitoring, and PAGCOR audit requirements.
• Anti-money laundering compliance: Monitoring transactions and player activity for indicators of money laundering or terrorist financing as required under Republic Act No. 9160 (Anti-Money Laundering Act) and PAGCOR AML circulars. Reporting suspicious transactions to the Anti-Money Laundering Council (AMLC).
• Responsible gaming: Monitoring usage patterns to identify potential signs of problem gambling; administering deposit limits, loss limits, self-exclusion, and cooling-off periods; and supporting player welfare interventions.
• Customer support: Responding to support requests submitted via live chat, handling account disputes, processing complaints, and maintaining records of support interactions.
• Security and fraud prevention: Detecting and investigating suspected fraud, cheating, multi-accounting, and other prohibited conduct under the a45.com Terms & Conditions.
• Platform improvement: Analysing aggregated and anonymised usage data to improve platform performance, game library curation, and user experience — without identifying individual players.
• Legal compliance: Complying with court orders, regulatory investigations, or other lawful requests from Philippine government authorities.

5.2   a45.com does not use your personal data to deliver personalised marketing from third-party advertisers. Any promotional communications from a45.com relate exclusively to the a45.com platform itself and are sent only to account holders who have not opted out of such communications.

6 Legal Basis for Processing

6.1   Under the Philippine Data Privacy Act of 2012, a45.com processes personal data on one or more of the following legal bases:

• Consent: Where you have provided explicit consent, such as at account registration or when opting into specific communications.
• Contractual necessity: Processing required to fulfil the agreement between you and a45.com as set out in the Terms & Conditions — including account operation, payment processing, and game delivery.
• Legal obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act (RA 9160), the Data Privacy Act (RA 10173), the National Internal Revenue Code, and other applicable Philippine laws.
• Legitimate interests: Processing necessary for fraud prevention, security monitoring, responsible gaming assessments, and platform integrity where your interests and rights do not override these legitimate interests.

7 Sharing Your Personal Data

7.1   a45.com does not sell your personal data. We share personal data only with the following categories of recipients, and only to the extent necessary for the stated purpose:

• PAGCOR: Mandatory regulatory reporting of player activity, transaction data, and PAGCOR audit requests. This sharing is required by the Operator's PAGCOR license and cannot be refused.
• Anti-Money Laundering Council (AMLC): Reporting of suspicious transactions as required by RA 9160. This sharing is legally mandated and does not require player consent.
• Payment processors: GCash, Maya, BPI, BDO, and other accepted payment providers receive the transaction data necessary to process deposits and withdrawals. Each provider operates under its own privacy policy and applicable Philippine banking regulations.
• Identity verification services: KYC verification data may be shared with certified identity verification providers operating under applicable Philippine data privacy requirements.
• Game content providers: Certified game providers (e.g., Pragmatic Play, PG Soft, Evolution Gaming, Jili) receive anonymised session and gameplay data necessary for game delivery and technical operation. No personally identifiable information is shared with game providers for their own marketing purposes.
• Legal authorities: Personal data may be disclosed to Philippine courts, law enforcement agencies, or government regulators in response to lawful orders, investigations, or legal proceedings.
• Professional advisors: Lawyers, auditors, and compliance consultants engaged by the Operator on a confidential basis where access to personal data is necessary for the advisory service.

7.2   All third-party service providers who process personal data on behalf of a45.com are bound by data processing agreements requiring them to handle personal data only on documented instructions and in compliance with applicable Philippine data privacy law.

8 Cookies and Tracking Technologies

8.1   a45.com uses cookies and similar browser-based storage technologies to operate the platform, maintain your login session, detect fraud, and analyse aggregate usage patterns. The following categories of cookies are used:

• Essential cookies: Required for platform operation, including session management, login authentication, and security features. These cannot be disabled without preventing access to the platform.
• Functional cookies: Store your preferences such as language settings and responsible gaming limit selections so these do not need to be re-entered on each visit.
• Analytics cookies: Collect aggregated, anonymised data about how players navigate the platform. This data is used to identify and fix technical issues and to improve the user experience. Individual players are not identified through analytics data.
• Security cookies: Used to detect and prevent fraudulent login attempts, bot access, and multi-accounting. These are essential for platform security and cannot be disabled.

8.2   a45.com does not use third-party advertising cookies or tracking pixels that share your data with advertisers. You can manage non-essential cookies through your browser settings; however, disabling essential cookies may prevent full access to the a45.com platform.

9 Data Security

9.1   a45.com implements technical and organisational security measures appropriate to the nature of the personal data processed and the risks associated with online gaming platform operations. These measures include:

• SSL/TLS encryption for all data in transit between your device and a45.com servers;
• Encryption of sensitive data at rest, including financial information and government ID data;
• Access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular third-party security audits as required by PAGCOR operational standards;
• Fraud detection and account monitoring systems that operate continuously;
• Incident response procedures for managing data security events in compliance with RA 10173 breach notification requirements.

9.2   While a45.com implements robust security measures, no online platform can guarantee absolute security against all threats. You are responsible for maintaining the security of your own a45.com account credentials and for logging out of sessions on shared devices.

10 Data Retention

10.1   a45.com retains personal data for the following periods, after which data is securely deleted or anonymised:

• Account and identity data: Retained for five (5) years after account closure, as required by PAGCOR operating conditions and the Anti-Money Laundering Act.
• Financial transaction data: Retained for five (5) years from the date of each transaction in compliance with PAGCOR and AMLC record-keeping requirements.
• KYC documentation: Retained for five (5) years after the player's last active transaction or account closure, whichever is later.
• Support interaction records: Retained for three (3) years from the date of the interaction, or for the duration of any related complaint, dispute, or regulatory investigation.
• Responsible gaming records: Self-exclusion and deposit limit records are retained for the full duration of their effect plus five (5) years to prevent circumvention and support PAGCOR responsible gaming reporting.
• Technical and usage logs: Server and session logs are retained for twelve (12) months for security and fraud investigation purposes.

10.2   Where retention beyond these periods is required by a court order, ongoing legal proceeding, or regulatory investigation, a45.com will retain the relevant data until the requirement is lifted.

11 Your Data Protection Rights

11.1   Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to personal data held by a45.com. All rights requests should be submitted to a45.com support via live chat or the DPO contact address in Section 16.

11.2   If you believe a45.com has not adequately addressed your data privacy rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph). a45.com will cooperate with any NPC investigation into its data processing practices.

12 Minors and Age Restrictions

12.1   a45.com is strictly prohibited to persons under the age of 21 years, as mandated by PAGCOR regulations applicable to casino-style online gaming in the Philippines. a45.com does not knowingly collect personal data from individuals under 21 years of age.

12.2   If a45.com discovers or has reason to believe that personal data has been collected from a person under 21 years of age, it will immediately close the associated account, forfeit any funds in accordance with PAGCOR regulations, delete the personal data of the underage individual, and report the matter to PAGCOR as required.

12.3   Parents or guardians who believe their child under 21 may have registered at a45.com should contact support immediately via live chat so that the account can be reviewed and closed if necessary.

13 Cross-Border Data Transfers

13.1   As an online gaming platform using internationally headquartered game content providers (such as Pragmatic Play, Evolution Gaming, PG Soft, and Jili), some personal data may be processed on servers located outside the Philippines. Where such transfers occur, a45.com ensures that appropriate safeguards are in place to protect your data to a standard at least equivalent to Philippine data privacy requirements.

13.2   Safeguards for cross-border data transfers may include: contractual clauses requiring recipient organisations to maintain RA 10173-equivalent protections; transfers only to jurisdictions recognised by the NPC as providing adequate data protection; or explicit consent obtained where required.

13.3   No personal data is transferred to a third country for the primary purpose of avoiding Philippine regulatory requirements.

14 Personal Data Breach Notification

14.1   In the event of a personal data breach that is likely to result in a real risk of serious harm to data subjects, a45.com will:

1. Notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required by NPC Circular 16-03;
2. Notify affected data subjects without undue delay where the breach is likely to adversely affect their rights and interests;
3. Document the breach, its effects, and the remedial actions taken in the Operator's data breach register.

14.2   Breach notifications to affected players will be sent to the registered email address or Philippine mobile number on the player's a45.com account. Notifications will clearly describe the nature of the breach, the data categories affected, the likely consequences, and the measures taken or proposed to address it.

15 Changes to This Privacy Policy

15.1   a45.com may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, PAGCOR regulatory requirements, or National Privacy Commission guidance. The effective date at the top of this page indicates when the current version took effect.

15.2   Where material changes are made to this Privacy Policy — changes that significantly affect how we use your personal data or your rights — a45.com will provide advance notice by displaying a prominent notice on the platform or by email to your registered contact address. Non-material changes such as typographic corrections or clarifications may be made without advance notice.

15.3   Continued use of the a45.com platform after the effective date of an updated Privacy Policy constitutes your acknowledgment that you have reviewed the updated policy.

16 Contact and Data Protection Officer

For any questions, rights requests, complaints, or concerns regarding your personal data and this Privacy Policy, please contact the a45.com Data Protection Officer. All contacts are available in English and respond to enquiries from Filipino players across all regions.

If your complaint is not resolved to your satisfaction by the a45.com DPO, you may file a complaint with the National Privacy Commission of the Philippines. The NPC accepts complaints from Philippine residents whose data privacy rights have been violated by a personal information controller or processor.